R-ATP Exemption Follow-Up

Back in 2014, I wrote about six different universities and a community college that were all petitioning the FAA to become exempt from the requirement to hold a ground school certification so that they could participate in the R-ATP program.

That post had become somewhat stale, so here is a look back at what happened in the past few years.

Petitions Denied

Chandler-Gilbert Community College was denied its exemption in November 2017 and as of May 2018 was not authorized to certify R-ATP applicants.

Metropolitan State University of Denver was denied its exemption in July 2014 and as of May 2018 was not authorized to certify R-ATP applicants.

Denied and Then Authorized

Baylor University was denied its exemption in December 2014 and later gained R-ATP authorization in February 2016.

Eastern Michigan University was denied its exemption in August 2015 and later gained R-ATP authorization in July 2016.

Jacksonville University formally withdrew its petition for exemption in September 2016 and gained R-ATP authorization later that same month.

Petitions Granted

Auburn University was granted its exemption in November 2015, allowing Part 61 students who graduated between August 2010 and December 2016 to apply for R-ATP.

Purdue University was granted its exemption in July 2014, allowing Part 61 students who graduated between January 2009 and December 2016 to apply for R-ATP.

R-ATP Cross Country Time

ATP Qualifications Job AidI previously wrote about a regulatory boo boo that made it impossible to determine how much cross country flying experience was required to obtain a restricted ATP certificate.  The regulation that allowed students to apply for the rating with 30 college credit hours was never included in the nearby paragraph authorizing reduced cross-country time requirements.

To bring some clarity to this issue, I can now point you to this official checklist: FAA ATP Qualifications

Although this checklist is not regulatory, it is published by the FAA and so shows the original intent of the R-ATP regulation to allow anyone with 200 hours of cross-country time to apply for reduced minimums.

Since FAR § 61.160(e) contradicts the above checklist, I still anticipate a future amendment to fix this regulation.

Restricted ATP Minimums

Easy-to-read details about the new ATP rules?  You found them!  I understand the need for simple explanations. There are six ways to get an ATP license now, each with different requirements.

This is my summary and comparison of the R-ATP minimums from 14 C.F.R. § 61.159 and § 61.160.

160 (a) 160 (b) 160 (c) 160 (d) 160 (f) 159
Age 21 years 21 years 21 years 21 years 21 years 23 years
Total Time as a Pilot 750 hours 1,000 hours 1,250 hours 1,250 hours 1,500 hours 1,500 hours
Cross-Country Time 200 hours 200 hours 200 hours see notes 200 hours 500 hours
Instrument Training Any § 141 § 141 § 141 Any Any
Commercial Training Any § 141 § 141 § 141 Any Any
Education Military Bachelor Associate Bachelor
Concentration Aviation Aviation Aviation
Certification see notes see notes see notes
Recognized Coursework 60 credits 30 credits 30 credits

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R-ATP Exemption for Part 61 Training

Logos of EMU, Jacksonville, MSU Denver, and Purdue.My searches on federal websites found four petitions by universities seeking R-ATP authorization without a required part 141 ground school certificate.

The petitioners are, in alphabetical order: Eastern Michigan University, Jacksonville University, Metropolitan State University of Denver, and Purdue University.

Letters and documents filed by these universities seem to be routine.  I will point out also that the Jacksonville petition included a copy of the university’s rejection letter from the FAA dated December 2013.

While the FAA is not currently accepting comments on these petitions, I would like to offer my encouragement.  The FAA should authorize these universities as rapidly as possible, recognizing they are accredited institutions that offer 4-year degrees with aviation concentrations.  This is the purpose and intent of the R-ATP program, after all.

Details and reference numbers are listed below, in chronological order.

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R-ATP Regulation to Reality

The newly-promulgated FAR 61.160 went into effect last week.  Already, I am seeing positive changes in the aviation industry.  Hiring is on a rapid up-swing, and rumors are starting to circulate about a liberal interpretation of the new first officer qualifications and certification rules.

While discussing the potential for a pilot shortage last year, I didn’t yet mention the combined effects of existing trends and the looming 1,500-hour minimum experience level for new first officers.  What was happening at the time, and slowly becoming problematic, was that the regional airlines were increasing their own hiring qualifications.  Those hiring policies were becoming restrictive faster than the country was producing ATP-qualified pilots.  Remember, before the Airline Safety Act of 2010 there was no requirement for regional airlines to hire ATP certified first officers.  But the Act required by August 1, 2013 that “all flight crewmembers have obtained an airline transport pilot certificate.”  The Act also required the FAA to issue its Final Rule on this by an August 1, 2012 deadline, which it failed to do.  This left airlines in the awkward position of hiring only those pilots who could obtain an ATP before the 2013 deadline.  Hiring slowed to near zero because there was a shortage of entry-level pilots who could accumulate 1,500 hours of flight experience.

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First Officer Qualification Rule in Detail

Cover page of the Federal Register for July 15.The new first officer qualifications are a hot topic.  On July 10, the FAA released its Final Rule, which should appear in the Federal Register next week.  Everyone has something to say about this.  But opinions aside, all I can I find on the web is the text of the new rule and several paraphrased copies of the FAA press release.

Let’s take a closer look at what’s inside the 221 pages of the Pilot Certification and Qualification Requirements for Air Carrier Operations.

To get the most important information up front here, I compiled a detailed summary of changes as they would apply to a graduate of a qualifying 4-year degree program.

I also outlined the structure of the Final Rule and noted the page numbers of some important sections.  The small page numbers correspond to the unofficial FAA version, followed in parentheses by the official page number in the Federal Register.  For example: Page 1 (42324).  This will help you to reference either version of the Final Rule.

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First Officer Epoch Next August

Rob visiting the captain's seat in a 747.
What are airline pilots really made of?

Pilot employment qualifications are changing.  For the potential first officer at a regional or major airline, this change will be huge.

Currently, the requirements for acting as a first officer or second in command (SIC) of an airliner are simple.  All it takes is a commercial pilot license.  The captain is required to have an airline pilot license, but not the first officer.  This is all laid out in the two paragraphs of the applicable regulation number 121.437.  A commercial pilot license can be obtained after meeting the minimum 250 hours of flight time experience.

Starting on August 1, 2013, the Airline Safety and Federal Aviation Administration Extension Act of 2010 will remove all commercial pilots from domestic, flag, and supplemental operations.  By itself, sec. 216(a)(2)(B)(i) of this Act would require “all flight crewmembers” to hold an airline transport pilot (ATP) certificate, which in turn requires at least 1,500 hours of pilot time experience.  That’s six times the current requirement to become a first officer.

The Federal Aviation Administration (FAA) is wisely using the time before August to develop a regulation that does not require 1,500 hours.  Its latest proposal, dated February 29, 2012, allows graduates of a 4-year degree program to obtain the needed license by meeting the following requirements:

Continue reading First Officer Epoch Next August